https://www.taxtmi.com/caselaws?id=784661 Where reassessment notices under ss.147/148 are founded on incriminating material seized in a search under ss.132/132A relating to a third party, the statutory scheme of ss.153A/153C (special provisions with overriding effect) governs. The HC held that recording of satisfaction by the AO of the searched person and transmission of such satisfaction with the seized material is a mandatory jurisdictional pre-condition for assumption of jurisdiction under s.153C; it is not a procedural formality. In the absence of such satisfaction, the AO of the "other person" cannot bypass s.153C and directly invoke ss.147/148 on the search material; such action is without jurisdiction and liable to be quashed. Reopening under ss.147/148 remains permissible only on independent, non-search material. en-us Wed, 07 Jan 2026 00:00:00 +0530 Fri, 09 Jan 2026 10:28:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784661 Where reassessment notices under ss.147/148 are founded on incriminating material seized in a search under ss.132/132A relating to a third party, the statutory scheme of ss.153A/153C (special provisions with overriding effect) governs. The HC held that recording of satisfaction by the AO of the searched person and transmission of such satisfaction with the seized material is a mandatory jurisdictional pre-condition for assumption of jurisdiction under s.153C; it is not a procedural formality. In the absence of such satisfaction, the AO of the "other person" cannot bypass s.153C and directly invoke ss.147/148 on the search material; such action is without jurisdiction and liable to be quashed. Reopening under ss.147/148 remains permissible only on independent, non-search material. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784661